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PRIVACY POLICY

We are concerned about privacy issues and want you to be familiar with how we collect,
use and share information we receive about our clients and users and the options available to you.
If you have any questions, you may contact us.

BidGear offers marketing automation for publishers via a selling platform, which enables publishers
to optimize their digital assets while protecting their brands. We are a publisher-focused company,
but at the same time we maintain client relationships with media buyers. As a user you may
encounter an ad from one of our media buyer clients by viewing the content on a website or
application owned or operated by one of our publisher clients.

SCOPE OF THIS PRIVACY POLICY

This Privacy Policy covers the information that we may collect or receive across
the Internet and other digital formats:

from users who (i) visit www.BidGear.com and other websites operated by us,
including BidGear’s client interfaces (the "Websites"), (ii) use our software applications
(the "Apps"), (iii) use our social media pages (collectively, our "Social Media Pages"),
and (iv) receive email messages that we send to you (collectively, the Websites,
Apps and Social Media Pages, the "BidGear Pages"); and

through our technologies used by our publisher clients, media buyer clients and third
parties that we use to gather and process information on their behalf (collectively,
including the Websites, the Apps and our Social Media Pages, the "Services").
In this second context, we act as processors for the clients who serve as the data
controllers for the information that we obtain from them.

We may change this policy from time to time. Please consult the Privacy Policy regularly for
updates.

PERSONALLY IDENTIFIABLE INFORMATION

Collection of Personally Identifiable Information from the BidGear Pages

"Personally Identifiable Information" is information that identifies you as an individual,
including: name, postal address, telephone number and email address. We and our third party service
providers may collect Personally Identifiable Information from you from the BidGear Pages. For example,
we collect your Personally Identifiable Information when you request information about the
Services through our client user interfaces or the "Contact Us" section of our Websites or the
"Featured Content" section of our Websites where you can download reports and white papers.

Use of Personally Identifiable Information

We and our third-party service providers may use Personally Identifiable
Information collected from the BidGear Pages:

to respond to your inquiries and fulfill your requests,

to send administrative information to you, for example, information
regarding the Services and changes to our terms, conditions, and policies,

to send you marketing communications that we believe may be of interest to you,

for our business purposes, such as data analysis, audits, fraud monitoring and prevention,
developing new products, enhancing, improving or modifying our Services, identifying usage
trends, determining the effectiveness of our promotional campaigns and
operating and expanding our business activities, and

as we believe to be necessary or appropriate: (a) under applicable law, including laws
outside your country of residence; (b) to comply with legal process; (c) to respond to requests
from public and government authorities including public and government authorities outside your
country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or
those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or
that of our affiliates, you or others; and (g) to allow us to pursue available
remedies or limit the damages that we may sustain.

Disclosure of Personally Identifiable Information

Your Personally Identifiable Information collected from the BigGear Pages may be disclosed:

among our affiliates (identified in the second paragraph of this Privacy Policy) for the
purposes described in this Privacy Policy. BidGear is the party responsible for the management
of the Personally Identifiable Information jointly used by it and its affiliates,

to our third-party service providers who provide services such as lead management, campaign
measurement and other services,

directly by you, on message boards, chat, profile pages and blogs and other services to which
you are able to post information and materials (including, without limitation, our Social Media
Pages). Please note that any information you post or disclose through these services will become
public information, and may be available to users of the Services and to the general public. We
urge you to be very careful when deciding to disclose your Personally Identifiable Information,
or any other information, on the Services,

to a third party in the event of any reorganization, merger, sale, joint venture, assignment,
transfer or other disposition of all or any portion of our business, assets or stock (including
in connection with any bankruptcy or similar proceedings), and

as we believe to be necessary or appropriate: (a) under applicable law, including laws outside
your country of residence; (b) to comply with legal process; (c) to respond to requests from
public and government authorities including public and government authorities outside your
country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or
those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or
that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit
the damages that we may sustain.

Retention of Personally Identifiable Information

We will retain your Personally Information for the period necessary to fulfill the purposes outlined in
this Privacy Policy unless a longer retention period is required or permitted by law.

OTHER INFORMATION

Collection of Other Information

"Other Information" is any information that is linked or reasonably linkable to a particular computer or
device, but does not reveal your specific identity or directly identify an individual, such as: browser
and device information; time spent on the Services, pages visited, language preferences, date and time
an ad was served, clicks on ads, and other anonymous traffic data; your precise location; unique
identifier, including mobile device identifier or statistical identifier; demographic information,
including physical information; information provided by you; and aggregated information.

We and our third party service providers may collect Other Information in a variety of ways, including
through: your browser or device; your mobile device identifier; the use of statistical identifiers
(which collect and use certain characteristics of your device to help us identify it over time); your
use of the Apps; the use of pixel tags and other similar technologies; your IP address; the aggregation
of information; and cookies (cookies are pieces of information stored directly on the computer that you
are using).

Our publisher clients may also collect information about you that they choose to pass to us either
directly through our Services or through application programming interfaces or APIs, when our services
connect to their systems. APIs are a particular set of rules and specifications that allow one software
program to access and make use of another software program. The information our publisher clients may
share includes network type of a user's device, year of birth, ethnicity (where permitted by law),
gender, and precise geo-location (where permitted by law). Some publisher clients may provide precise
geo-location information collected on certain platforms. We will not use precise geo-location
information for Interest-Based Advertising without your opt-in consent.

Use of Other Information

We may use Other Information from the Services:

to operate, improve, analyze and manage the Services,

to ensure the Services function properly,

for advertising purposes, such as using an identifier for interest-based advertising and ad
delivery and reporting across websites, online services, and apps over time, including
optimization of location of ad placement, ad performance, reach and frequency metrics, fraud
prevention, billing, logging the number and type of ads served on a particular day on a device,

to track the actions of users of the Services, measure and report on the success of marketing
campaigns via pixel tags (also known as web beacons and clear GIFs),

to identify and probabilistically recognize the same device at a later point in time for
purposes of sending advertising or content to that device in mobile apps (using statistical
identifiers),

to calculate usage levels of the Services, helping diagnose server problems and administer the
Services via your IP Address (a number automatically assigned to the computer or device that you
are using by your Internet Service Provider),

to provide you with personalized location-based services and content through the use of your
device’s physical location (where permitted by law),

to track delivery of an ad impression,

to track your use of the Services to improve the design and functionality of the Services,

to supplement Other Information with additional information we receive from third parties such
as advertising segments to allow us to target ads to you that may be of interest to you,

for security purposes, to facilitate navigation, display information more effectively, and to
personalize your experience while using the Services, and

as we believe to be necessary or appropriate: (a) under applicable law, including laws outside
your country of residence; (b) to comply with legal process; (c) to respond to requests from
public and government authorities including public and government authorities outside your
country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or
those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or
that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit
the damages that we may sustain.

We may partner with certain third parties to collect Other Information to engage in analysis, auditing,
research, and reporting, as well as to deliver advertising that we believe may interest you based on
your activity on our website and other websites over time. These third parties may set and access
cookies on your computer or other device and may also use web logs or web beacons.

At this time, we do not honor "Do Not Track" headers and similar mechanisms.

We will not use data we collect for the purpose of determining employment eligibility, credit
eligibility, health care eligibility, or insurance eligibility and underwriting and pricing.

We will not collect or use sensitive data, such as Social Security Numbers or Government identifiers,
insurance plan numbers, financial account numbers; information about past, present, or potential future
health or medical conditions or treatments, including genetic, genomic, and family medical history; and
sexual orientation unless we have obtained your prior consent.

We may receive the following non-sensitive health-related advertising segments that we use to target ads
to you that may be of interest to you: diet and fitness; doctors; health care professionals; health
conscious; health and medicine; health and well-being; interest in health insurance; and pregnancy.

Disclosure of Other Information

We may disclose Other Information:

among our affiliates (identified in the second paragraph of this Privacy Policy) for the
purposes described in this Privacy Policy,

to our client publishers to allow them to analyze the effectiveness and performance of our
services and to offer targeted ad inventory to our media buyer clients,

to our media buyer clients to allow them to make decisions regarding buying advertising
inventory on our publisher clients' websites, other websites, and applications, and to analyze
the effectiveness and performance of their advertising campaigns via our services, including
sharing your device’s physical information to enable our media buyer clients to provide you with
more personalized content and to study the effectiveness of advertising campaigns,

to our third-party service providers who provide services that enhance our services, and

as we believe to be necessary or appropriate: (a) under applicable law, including laws outside
your country of residence; (b) to comply with legal process; (c) to respond to requests from
public and government authorities including public and government authorities outside your
country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or
those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or
that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit
the damages that we may sustain.

In some instances, we may combine Other Information with Personally Identifiable Information (such as
combining your name with your geographical location). If we combine any Other Information with
Personally Identifiable Information, the combined information will be treated by us as Personally
Identifiable Information as long as it is combined. We will not use PII merged with previously-collected
Other Information for Interest-based advertising purposes without your opt-in consent.

Retention of Other Information

We retain Other Information we collect for purposes of serving targeted advertisements to you (including
the segment information that we receive from third parties) for up to 90 days, unless we have not
received any segment data for a user for 30 days, in which case the data for that user is no longer
retained at that point in time. We retain impression information for up to six months. We retain raw ad
server logs for our mobile ad server business for up to 9 months. We use precise geo-location for the
specific ad impression to which the geo-location relates, after which the geo-location information is
aggregated with other geo-location data for use by us for analytical purposes. If we de-identify Other
Information we collect in connection with targeted advertising purposes, we may retain that information,
in an aggregated format, indefinitely. In such cases, we commit to not re-identifying the information.

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose, any sensitive Personally Identifiable Information
(e.g., social security numbers, information related to racial or ethnic origin, political opinions,
religion or other beliefs, health, criminal background or trade union membership) on or through the
Services or otherwise to us.

THIRD PARTIES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other
practices of any third parties, including our vendors or any other third party operating any site or
service to which the Services link. The inclusion of a link on the Services does not imply endorsement
of the linked site or service by us or by our affiliates.

Please note that we are not responsible for the collection, usage and disclosure policies and practices
(including the data security practices) of other organizations, such as app developer, app provider,
social media platform provider, operating system provider, wireless service provider or device
manufacturer, including any Personally Identifiable Information you disclose to other organizations
through or in connection with the Services.

You should always read the privacy policy of any website you access or social network page through which
you share information carefully in order to understand their specific privacy and information usage
practices.

SECURITY OF PERSONALLY IDENTIFIABLE INFORMATION

We seek to use reasonable organizational, technical and administrative measures to protect Personally
Identifiable Information within our organization. Unfortunately, no data transmission or storage system
can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no
longer secure (for example, if you feel that the security of any account you might have with us has been
compromised), please immediately notify us of the problem by contacting us in accordance with the
"Contact Us" section below.

USE OF SERVICES BY MINORS

BidGear Services are not intended for nor directed to individuals under the age of thirteen (13), and we
request that these individuals do not provide Personally Identifiable Information through any of the
Services.

CONTACT US

If you have any questions about this Privacy Policy or BidGear privacy practices, please contact us by
email at [email protected]